I am quite sure that if the way he did it is the way they actually reported it, then, there are serious compliance department problems at big banks in the USA.

1. Money laundering is always, always an issue. Become familiar with the standard terms for money laundering, especially layering and integration.

2. If you deposit small amounts at the same time in various banks you will raise flags, it is called a Suspicious Transaction and must be reported. There are other activities that fall under Suspicious Transaction Reports.

3. As I said before, even electronically transmitted currency is some times detained for a day or so to be analyzed by the US designated agencies and then released. Why do you
think they do so?

4. I agree, there is no problem putting Bolivars in a Venezuelan account in Venezuela. The banks are so laxed with their rules that anyone can make any story and put money anywhere.

Sub Accounts are not the same as actual accounts.

1. Vyasulu would have to go to the same bank or banks and opened multiple accounts, BUT, one has to fill out a money transmitting form plus a number of other documents and send them to the Compliance Department of the bank. In the form, one specifies the license number, Tax ID number, and type of money transmitting business.

2. Vyasulu had a money transmitting license attached to Rosemont P, (not A, B…Z). The money transmitting license says Rosemont P and the bank will make sure to record the company as Rosemont P (not A…Z). They are very detailed when it comes to money transmitting businesses.

3. Vyasulu had only one money transmitting license which can be used only for one money transmitting account.

4. One cannot have more than one money transmitting license, it is not allowed.

5. Unless, Vyasulu used 25 or so banks and gave each the same money transmitting license, there is no other way, in which case the IRS would have asked him a few questions way early on.

6. Therefore, the sub-accounts would have to be either: (a) A large number of Rosemont P actual acccounts each belonging to a different bank but tied to the same Tax ID and money transmitting license number or (b) One actual account and a number of “sub-accounts” all belonging to the same actual account. One of the few banks that provide an easy way to create this structure is BOA. The bank that had the “sub-accounts” belonging to a “parent account”.

7. In my opinion, there is confusion between sub-accounts and actual accounts. Sub-accounts all belong to the same actual account, but they do not belong to separate banks.

Even worse, money transmittal licenses are only supposed to be for that, transmitting funds, but Rosemont would keep millions of dollars for weeks, while the law says you should not have it for more than 5 days.

Therefore, the issue of money laundering is not an issue.

The following is just for the sake of argument….

My being paid in Venezuela by check, I don’t see any issues. Why would that be an issue? If I deposit a Venezuelan check into my Venezuelan account, why is anybody going to ask me about the source of funds? I suppose I would just explain that this is just a check to pay me for a loan, or something else. What the heck?

http://www.bankofamerica.com/small_business/online_banking_and_services/index.cfm?template=online_business_suite